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NCAT's Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices


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NCAT's Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices

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NCAT's Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices

  1. 1. NCAT’s Organic Livestock Workbook A Guide to Sustainable and Allowed Practices NCAT NCAT’s Organic Livestock Workbook is designed for use by organic and transitional producers with livestock or mixed crop and livestock operations. Producers having certified or transitional cropping enterprises should also utilize NCAT’s Organic Crops Workbook.1 This workbook series is intended to be consistent with the requirements of the National Organic Standard. This document was developed by the National Center for Appropriate Technology (NCAT) with funds provided by the USDA/National Organic Program (NOP), and the USDA/CREES Sustainable Agriculture Research and Education (SARE) Program. Distribution is provided by NCAT’s ATTRA Project, the National Sustainable Agriculture Information Service. Rotational Grazing with Holstein dairy cattle, Washington County, Virginia. By Jeff Vanuga. 2002. USDA Natural Resources Conservation
  2. 2. Revised February 2004 Page 2 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Contents Acknowledgements ........................................................................................................................................................... 3 The Purpose and Use of This Workbook........................................................................................................................ 4 Fundamentals I. Organic Agriculture in America .................................................................................................................... 5 II. Certification ...................................................................................................................................................... 6 III. Overview of Organic Livestock Systems...................................................................................................... 7 IV. Organic System Plan ..................................................................................................................................... 11 V. Adjoining Land Use ...................................................................................................................................... 14 VI. Supporting BioDiversity ............................................................................................................................... 16 Pastures and Hay Crops VII. Organic Soil Management for Pasture and Hay Crops ............................................................................ 18 VIII. Weed Management in Pasture and Hay Crops ......................................................................................... 24 IX. Pest and Disease Management in Pasture and Hay Crops...................................................................... 28 X. Seeds and Planting Stock .............................................................................................................................. 29 XI. Field Equipment............................................................................................................................................. 32 XII. Hay and Haylage Harvest ............................................................................................................................ 34 XIII. Monitoring Your Pasture’s Performance.................................................................................................... 34 Livestock Health and Management XIV. The Organic Approach to Livestock Health .............................................................................................. 36 XV. Organic Feed .................................................................................................................................................. 38 XVI. Livestock Living Conditions, Facilities, and Handling ............................................................................ 41 XVII. Manure Management .................................................................................................................................... 46 XVIII. Physical Alterations ....................................................................................................................................... 49 XIX. Treatment of Sick or Injured Livestock....................................................................................................... 50 XX. Internal and External Parasite Management ............................................................................................. 52 XXI. Assessing the Vitality and Health of Your Organic Livestock ................................................................ 55 XXII. Predator Management .................................................................................................................................. 57 Organic Integrity and Related Matters XXIII. Source of Animals .......................................................................................................................................... 58 XXIV. Feed Storage ................................................................................................................................................... 61 XXV. On-Farm and Custom Feed Processing or Handling ............................................................................... 63 XXVI. On-Farm and Custom Livestock Processing or Handling ....................................................................... 65 XXVII. Packaging and Labeling................................................................................................................................ 70 XXVIII. Marketing ....................................................................................................................................................... 71 XXIX. Documentation, Record Keeping, and Audit Trail ................................................................................... 72 Finding Referenced Information Sources ..................................................................................................................... 75 Cooperative Extension Publications Offices and Websites ....................................................................................... 79 Endnotes............................................................................................................................................................................ 84
  3. 3. Revised February 2004 Page 3 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Acknowledgements NCAT wishes to thank the Independent Organic Inspectors Association (IOIA)2 for permission to adapt its materials in developing this workbook series. Particular mention should be made of the publication IFOAM/IOIA International Organic Inspection Manual, compiled and edited by Jim Riddle and Joyce Ford. NCAT also wishes to acknowledge the members of the stakeholder team that guided the creation of this document. The stakeholder team includes: • Harriet Behar, farmer, organic inspector, and OMRI, Gays Mills, WI • Diane Bowen, IFOAM, Milwaukee, WI • Emily Brown-Rosen, Organic Materials Review Institute, Titusville, NJ • Lisa Cone, Waterfall Hollow Farm, Berryville, AR (co-author) • John Foster, organic inspector, OMRI, and Seven Spoke Farm, McMinnville, OR • Keith Jones, Director of Program Development, National Organic Program • Mark Keating, Agricultural Marketing Service, USDA, Washington, DC • Rose Koenig, Rosie’s Organic Farm and NOSB, Gainesville, FL • Nick Maravell, Nick’s Organic Farm, Potomac, MD • Miles McEvoy, Washington State Department of Agriculture, Olympia, WA • Jim Riddle, Organic Independents and NOSB, Winona, MN • Maria Rosmann, Rosmann Family Farms, Harlan, IA • Kelly Shea, Director of Organic Agriculture, Horizon Organic, Penrose, CO • Francis Thicke, Radiance Dairy, Fairfield, IA NCAT staff that participated in the development of this workbook include: • Katherine Adam, Fayetteville, AR • Cynthia Arnold, Fayetteville, AR • Janet Bachmann, Fayetteville, AR • Rex Dufour, Davis, CA • Lance Gegner, Fayetteville, AR • Gail Hardy, Fayetteville, AR • George Kuepper, Fayetteville, AR (project leader) • Nancy Matheson, Helena, MT • Teresa Maurer, Fayetteville, AR • Cathy Svejkovsky, Butte, MT • Ann Wells, Fayetteville, AR NCAT does not recommend or endorse products, companies, or individuals. NCAT has offices in Fayetteville, Arkansas; Butte, Montana; and Davis, California. For additional copies of this publication, contact: ATTRA, P.O. Box 3657, Fayetteville, AR 72702; 1-800-346-9140.
  4. 4. Revised February 2004 Page 4 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices So here’s the scoop… The Purpose and Use of This Workbook One of the greatest challenges in organic farming today is understanding and navigating the Organic Regulations. This workbook3 is designed to help you in this regard. It addresses, among other things, the wide range of practices and materials allowed under the National Organic Standard. Particular em- phasis is placed on those farming strategies and practices that promote sustainability.4 This workbook will be especially useful to producers contemplating conversion to organic production, and to those who are in the early years of transition. If you are a beginning farmer or rancher, or are contemplating conver- sion to organic production, we encourage you to read this workbook before completing your application for certification. Please note that this is NOT a required document; it is a helpful guide that you may use as you wish. Hint: Your certifier would love to know you are using this workbook for guidance; consider showing it to your inspector.5 And speaking of organic inspectors, as you will learn in this workbook, organic inspection is an annual process. The individual who conducts the inspection—the organic inspector—represents the certifying agent. It is the inspector’s responsibility to look for documentation and indicators that bear out the producer’s claim to organic status, as well as to look for any violations. To succeed at their job, organic inspectors are trained to look critically at all aspects of an organic operation; few details escape their notice. This workbook presents an inspector’s perspective and attempts to address all of the different areas that inspectors investigate while visiting a livestock operation. Much of the useful information in the workbook is presented as brief discussions. Numerous endnotes are provided; most of these suggest further sources of information. You will also find a number of ques- tions at the end of each section, which serve as a checklist for sustainable practices and for preserving organic integrity. There are a number of questions that draw particular attention to areas that may affect eligibility for certification. In most instances the pertinent section and paragraph of the Organic Regula- tions will be shown in brackets, for example, [§205.203(c)]. Consider each of the questions carefully and place a check in the appropriate “Yes,” “No,” or “Not Appli- cable (n/a)” box. Providing answers that accurately reflect your current circumstances will be the most helpful to you—honesty will be your best policy. Ideally, you will have most of your checks in the “Yes” boxes. If you want to make optimum use of this workbook as a guide to information sources, try using the electronic versions (.html and .pdf) of the workbook that can be found on the ATTRA website at <http:/ />. The workbook is featured under the section on organic farming. The publica- tions referenced in the endnotes are mostly free-of-charge resources accessible on the World Wide Web, and are active hypertext links. Clicking on any of these links will “jump” you immediately to that re- source. But be aware, electronic addresses can change. If a link does not work for you, submit your request to the appropriate entity—State Cooperative Extension Office, ATTRA, or other. A contact list for the primary information providers and Extension Publication Offices can be found toward the end of the workbook. Please note that some resources listed in the endnotes may not be fully consistent with the National Organic Standard. For example, Cooperative Extension Publications on organically acceptable pesti- cides often include nicotine, which is now specifically prohibited. When you have a question about whether any practice or product is allowed in organic production, CONSULT YOUR CERTIFIER. This is advice we will frequently give throughout this workbook.
  5. 5. Revised February 2004 Page 5 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices I. Organic Agriculture in America There are many notions of what organic agriculture is. In 1995, the National Organic Standards Board defined it as “an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and on man- agement practices that restore, maintain and enhance ecological harmony.” The legal definition, provided in the National Organic Program Regulations, states that “Organic pro- duction [is] a production system that… respond[s] to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biological diversity” [§205.2]. While these definitions are helpful, they have more meaning when one considers them in light of how organic farming and the organic marketplace evolved. Contemporary American organic farming has its roots in the humus6 farming movements that prolifer- ated in Great Britain and Continental Europe from the 1920s through the 1950s. These movements evolved largely in response to the increasing use of synthetic fertilizers. The proponents of humus farming be- lieved that the highest quality food and the sustainability of agriculture were achieved through systems and techniques that built and enhanced the living organic or humus complex of the soil. Humus farming was typified by mixed farms that had both livestock and crop enterprises; they featured cropping schemes that included both food and feed crops, plus legume and grass forages and green manure crops. Humus farming made little or no use of soluble commercial fertilizers or pesticides, in good part because they were not needed and could even be counterproductive in systems so-modeled on nature.7 The 1960s and 1970s brought more visibility to organic farming as public concern over pesticide use increased. The non-use of synthetic pesticides eventually became a major focus of organic agriculture as demand for organic products grew, creating an industry out of a practical philosophic movement. Or- ganic industry growth led to the establishment of standards and third-party certification to ensure con- sistency and enhance credibility. As the industry expanded during the 1980s, disparities among certifier standards, barriers to trade, and incidents of fraudulent marketing led many to believe that more regulation was needed. Finally, in 1990, Congress passed the Organic Foods Production Act (OFPA).8 The OFPA mandated creation of the Na- tional Organic Program (NOP) and an advisory body, the National Organic Standards Board (NOSB). The OFPA paved the way for creating a single set of US standards for organic production, labeling, and marketing, which now exists in the form of the National Organic Program Regulations, a.k.a. the Na- tional Organic Standard.9 Many other countries, such as the European Union and Japan, have their own organic standards for products produced in or imported into their countries. US organic producers plan- ning to export their products must take these standards into account when certifying their operations.
  6. 6. Revised February 2004 Page 6 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices II. Certification Certification under the National Organic Program is the license to label, represent, and market your products as organic. Certification can be obtained from state or private certifiers that are accredited through the National Organic Program and who act as its licensing agents. 10 Under the NOP Regulations, all operations or portions of operations that produce or handle agricultural products that are intended to be sold, labeled, or represented as organic must be certified. Noncertified producers who represent themselves or their products as organic risk prosecution and fines. A three-year conversion period is required to achieve full organic status. In other words, no prohibited substances may be applied to the land for 36 months prior to the harvest of any product that will be labeled or otherwise represented as organic [§205.202(b)]. If you are purchasing or renting land that is not currently certified and you wish to document that it has not had prohibited substances applied, you must obtain verification from the previous landowner or manager.11 Annual inspections are part of the certification process. The inspector is an agent of the certifier. It is the inspector’s responsibility to look for documentation and indicators that bear out the producer’s claim to organic status, as well as to look for any violations. You must allow the inspector complete access to your operation, including all production facilities and offices [§205.400(c)]. Additional inspections may be announced or unannounced at the discretion of the certifier or the state organic program [§205.403(a)(2)(iii)]. Once certification has been granted, it is granted in perpetuity unless surrendered, suspended, or re- voked. For certification to continue, annual certification fees must be paid, the Organic System Plan (see section IV of this workbook) must be updated yearly, and previous non-compliances must be addressed [§205.406]. Any action to suspend or revoke certification must be handled in the manner prescribed in the Standard in §205.660–§205.664. If the status of your certification is threatened and you wish to dispute it, the process for seeking mediation is specifically covered under §205.663. Further details of these provisions will not be addressed in this workbook, but you should be aware that a formal grievance process exists. Producers who market less than $5000 of organic products annually are not required to apply for organic certification. They must, however, comply with the organic production and handling requirements of the National Standard. The products from such noncertified operations cannot be used as organic ingre- dients in processed products that are sold, labeled, or represented as organic by another operation; such noncertified products are also precluded from displaying the USDA organic seal. It is important to recognize that organic certification addresses the process involved in producing and handling a product. Organic certification assures the consumer that the product was grown using or- ganic methods, that harmful or dangerous pesticides, fertilizers, and genetically engineered organisms were not used in production, and that precautions were taken to prevent contamination from the outside. It does not guarantee that the product is completely free of all pesticide residues or GMO contamination. (The vast proliferation of pesticides and GE crops precludes virtually everyone from making such a claim.) Organic certification also does not ensure that the products are nutritionally superior.12 How- ever, organic farmers and consumers firmly believe that organic food and feed is healthier, and that organic production is better for the environment.
  7. 7. Revised February 2004 Page 7 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 2.1 Do you have a copy of the National Organic Standard13 and/or the standards of your certifying agency readily accessible as hardcopy or “bookmarked” on your web browser? 2.2 Is/Are your certifier(s) accredited by the National Organic Program? 2.3 Did you advise your certifier(s) of any previous applications for certification, including the names of the certifiers, dates of application, and the outcomes of those applications [§205.401(c)]? 2.4 If you are updating your certification, have you addressed any and all non- compliance issues and conditions previously noted by the certifying body [§205.401(c)]? 2.5 Have you discussed any previous suspensions or denials of organic certi- fication with your certifier [§205.401(c)]? Notes on Certification III. Overview of Organic Livestock Systems Traditional Organic Livestock Systems. Historically, livestock have always played a key role in organic production systems. During the formative years of the organic movement (the 1920s through the 1950s), the typical organic farms of Great Britain, Continental Europe, and North America integrated livestock production with the growing of both food and feed crops. Livestock provided manure, which is one of nature’s best fertilizers and a good means for recycling nutrients within a crop rotation. Growing live- stock feed alongside food crops diversified rotations; since forage legumes and sod-forming grasses are among the best feeds for ruminant livestock, these soil-building crops naturally became part of long sustainable cropping sequences. In such systems, livestock could also be fed cull vegetables, weather- damaged crops, crop residues, “alternative” grains and forages, and cash crop grains during years of low n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  8. 8. Revised February 2004 Page 8 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices prices. Traditional organic farming systems such as these migrated to the US and remain today. They are common throughout the upper Midwest, with beef, hogs, and dairy cattle as the principal livestock compo- nents, and corn, soybeans, small grains, and hay as the principal crop enterprises. Such traditional farms have been the subject of much study over the past few de- cades. When contrasted with comparable conventional farms they were found to use less fossil fuel energy, lose less soil to erosion, generate fewer groundwater pollut- ants, and have less impact on global warming—all char- acteristics of a more sustainable approach to agricul- ture.14 In this traditional organic model as it is practiced today, ruminant livestock have access to pasture, and confine- ment is allowed only on a temporary basis. Non-rumi- nants (hogs, for example) might be pastured, and vary- ing degrees of limited and temporary confinement are commonly used. In most instances, these traditional models adhere easily to the National Organic Program Regulations. Grazing systems might also be considered traditional organic livestock systems. Grazing systems exist in stark contrast to conventional confinement systems where all feedstuffs are harvested, transported, and bunk-fed to the livestock. In grazing systems, livestock go where the feed grows and harvest it themselves. This typically yields savings in both energy and equipment expense. Since most planned grazing systems are legume and grass forage-based, they also have less erosion and lower production input costs. Because grazing sys- tems naturally afford livestock access to the outdoors, sunlight, fresh air, and exercise, and because ma- nure is distributed naturally, grazing systems generally have few problems complying with the NOP Regulations. The principal challenge appears to be successful organic management of internal parasites. While most grazing systems might be classed as traditional, noteworthy contemporary strategies include management intensive (rotational) grazing15 and pastured poultry production.16 Alternative Organic Livestock Systems—Semi-Confined. Nontraditional models of organic livestock production featuring limited confinement have evolved in recent years. Among these alternatives are specialized semi-confined production systems with little or no landbase. Such systems resemble conven- tional confinement production, but are typically less crowded and allow the livestock access to the out- of-doors, to fresh air, and to sunlight. Semi-confined/non-landbase systems are allowed under the NOP Regulations for non-ruminant livestock production and may be used for ruminants on a temporary basis (see below). A major challenge faced by semi-confined/non-landbase systems is the handling of manure. According to the NOP Regulations, manure must be managed “in a manner that does not contribute to contamina- tion of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients” [§205.239(c)]. Production systems that do not have growing crops to fertilize must dispose of manure in an environmentally sound manner that ensures recycling of the nutrients it con- tains. Text Box 3A When Pasture is Pasture… or Not The National Organic Standard defines pas- ture as “[l]and used for livestock grazing that is managed to provide feed value and main- tain or improve soil, water, and vegetative resources” [§205.2]. Dry lots, which have little or no vegetation, do not meet the NOP definition of pasture; neither does over- grazed pastureland, since overgrazing de- grades “soil, water, and vegetative re- sources.” Since §205.239(a)(2) requires that ruminants have access to pasture, the NOP definition of pasture works to ensure that farms and ranches not exceed the carrying capacity of their land because the resulting overgrazing risks damage to the natural re- source base. It is OK to provide certified organic green chop, hay, and other feedstuffs, but this does not preclude the need to provide pasture access to ruminant stock. Certifiers and their inspector repre- sentatives are likely to question the certifiability of any system that maintains more ruminant stock than can be sustained on the available grazing acreage, under typi- cal seasonal constraints.
  9. 9. Revised February 2004 Page 9 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Another major challenge for semi-confined/non-landbase systems is the acquisition of sufficient quanti- ties and variety of organic feeds17 and bedding, since these are not produced on-farm. It is hoped that this problem will solve itself as organic production of feed grains and hay expands nationally. Temporary Confinement. Full confinement of livestock is allowed ONLY on a temporary basis in organic production [§205.239(b)]. The circumstances under which temporary confinement is permitted are spe- cific: • to protect animals from inclement weather • to accommodate the needs of a particular stage of production • to ensure the health, safety, and well being of the animal • to protect soil and/or water quality Text Box 3B A Pattern for Health and Sustainability As organic agriculture moves into the mainstream of commerce and culture in the United States and growing emphasis is placed on issues of compliance and marketing, we often lose sight of those aspects of organics that make it attractive and worthy of pursuit. One of the most compelling aspects is system health. It is well-known that most organic farmers and ranchers take pride in the health of their livestock and brag openly about how much they save on veterinary costs. Health management is not relegated solely to medical treatment of sick animals, but to the creation of a whole system that draws from the lessons of nature and optimizes livestock welfare; a system that not only minimizes the hazards of disease, but supports a strong natural immune response in those instances where stress and pathogens occur. The strategies that support this arise from an organic philosophy that traces human and animal health back to the soil and sees it as the foundation on which a healthy system must be built (see Figure 1 in this section). Furthermore, organic management does not seek maximum production; it does not push livestock above and beyond the natural and healthy levels of performance. Rather, organic husbandry seeks its payoff as a benefit from enhancing and optimizing the health of the flock, the herd, the soil—the whole farm system. Traditional organic systems—as described in the main text—reflect these strategies and philosophy. In the hands of good stewards, traditional or- ganic systems are essentially healthy, though they can always be improved upon—a good example being the integration of improved pasture grazing management. Major problems in organic livestock production tend to appear when producers attempt to adapt confinement livestock production to organics by merely “tweaking” the system. These folks might meet the minimum regulatory requirements, but they will always be challenged by animal health issues and the associated costs of treating sick livestock or sustaining high death losses. The health of a good organic system is not only reflected in the economic sustainability of the opera- tion, but also in its environmental sustainability. This is especially true as regards manure manage- ment and nutrient recycling. Figuring out what to do with all that manure is much less of a problem when the production system is land-based; there is not only a place for it to go, but all that waste becomes valuable fertilizer.
  10. 10. Revised February 2004 Page 10 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 3.1 Does your production system allow access to the out-of-doors, sunlight, fresh air, and exercise space for all your livestock [§205.239(a)(1)]? 3.2 Does your production system allow access to pasture for all ruminant livestock under usual conditions [§205.239(a)(2)]? 3.3 If you use temporary confinement, does it meet the criteria of the National Standard [§205.239(b)]? Notes on Livestock Systems n/a Yes No n/a Yes No n/a Yes No The Organic Concept of Animal Health through the Eyes of a Veterinarian. Adapted from Ann Wells, DVM (NCAT), 2003. Originally adapted from Johnson, in Benson & Zirkel’s Organic Dairy Farming, 1995. Figure 1. Medications Equipment Housing Breeding Water Pastures and Grazing Management Soil Life and Balance
  11. 11. Revised February 2004 Page 11 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices IV. Organic System Plan In comparison to many of the industry standards that preceded it, the National Organic Standard is much less prescriptive—that is, it tends to characterize what an organic operation should be like in gen- eral terms and leaves the details for producers and certifiers to work out. The principal tool for working out such details is the Organic System Plan. Under the National Organic Standard, each certified organic farm or ranch must have an Organic System Plan (OSP), also referred to as the organic farm systems management plan or the organic production and han- dling system plan. The OSP is a detailed outline that explains how you intend to operate your farm or ranch to satisfy the requirements of the NOP Regulations. According to §205.201(a) of the National Standard, the OSP must contain: • a description of farm practices and procedures to be performed and maintained, including the frequency with which they will be performed; • a list of each substance to be used as a production or handling input, indicating its composi- tion, source, location(s) where it will be used, and documentation of commercial availabil- ity, as applicable; • a description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effec- tively implemented; • a description of the record keeping system implemented to comply with the requirements established in §205.103; (See Text Box 4A in this section.) • a description of the management practices and physical barriers established to prevent commingling (see Text Box 4B in this section) of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and prod- ucts with prohibited substances; and • additional information deemed necessary by the certifying agent to evaluate compliance with the regulations. Text Box 4A Requirements for Recordkeeping §205.103 deals with the requirements for recordkeeping by certified operators. The records must: 1) be well-adapted to the business being conducted, 2) disclose all activities and transactions in adequate detail, 3) be maintained for not less than five years beyond their creation, and 4) be sufficient to demonstrate compliance with federal regulations. Your records must also be available for inspection and copying during normal business hours by authorized representatives of the Secretary of Agriculture, the State Organic Program, and/or the certifying agent [§205.103(c)].
  12. 12. Revised February 2004 Page 12 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The OSP must be written by the producer and agreed to by the certifier. It must reflect all current produc- tion methods and all materials that will be used. Producers should use the OSP to explain and rationalize practices they feel they need to manage effectively—especially those which may not have clear accep- tance in the National Standard. For example, physical alterations (castration, ear notching, nose rings, branding, beak trimming, etc.) are not provided blanket approval, though some organic producers may have used them for years. These producers can use the OSP to make their case for such practices, explain- ing why each practice is necessary, how it affects the animal’s welfare, and how it will be done to mini- mize stress and suffering. The certifier can then decide whether each practice complies with the Federal Standard. The OSP should also address future intentions and improvements. The OSP can be a vital tool for good organic management while ensuring compliance with the National Standard. Should you need to deviate from the OSP that you have agreed upon with your certifier, it is imperative that the certifier be advised [§205.406(a)(1)(i)]. It is required that you consult your certifier about planned changes in advance [§205.406(a)(1)(ii)]. An annual update of the plan is a requirement for continuation of certification [§205.406(a)(1)]. Text Box 4B Coming to Terms Contamination can be defined as contact or pollution with a prohibited substance; for example, con- ventional pesticides, GMO pollen. Commingling is the physical contact and possible mixing of an organic product with a similar con- ventional product. Transitional land is acreage that has been managed organically for less than 36 months. Because the term “transitional” does not have legal status in the National Organic Standard, crops harvested from transitional land may not be sold, labeled, or represented as “transitional;” neither may live- stock that have been fed transitional feeds. The status of such crops and livestock is, for all intents and purposes, conventional. Split production farms are those that produce both organic and nonorganic products (nonorganic includes transitional products). Parallel production is essentially a subset of split production. The term is used to describe a situation where the same crop or type of animal is produced both organically and nonorganically on the same farm operation. Paddock is a grazing unit in management intensive or rotational grazing systems. However, for the purposes of this workbook, paddock will simply refer to any pasture, field, or range unit where any form of grazing is practiced. Grazier is the term used to refer to one who manages grazing animals. Grazer (note the slight differ- ence in spelling) is used to describe the grazing animal itself.
  13. 13. Revised February 2004 Page 13 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices It is standard practice for the OSP to be incorporated in the application for certification, which is required by certifiers at the outset. In other words, you are completing your OSP at the same time you are filling out your application for certification. In such instances, a separate System Plan document is not required. There may also be some instances in which plans submitted to qualify for federal aid or assistance pro- grams may satisfy the requirement for an Organic System Plan [§205.201(b)].18 An accurate map of all farm or ranch acreage and production units is typically required as part of the OSP.19 Important map features: • consistent scale (Farm Service Agency photo maps may be used) • permanent field, pasture, or paddock numbers or names • permanent housing unit numbers • feed storage areas • buildings, roadways, and similar features • hydrologic features: wells, rivers, ponds, irrigation ditches, springs, major drainages, water- ways • field boundaries and adjoining land use • buffer zones • contiguous non-production areas under your ownership or management (for example, wild- life habitat, woodlot, etc.) Field or rangeland histories are also required as part of the OSP. Field histories should document: • field or paddock size • vegetation, crops and/or cover crops for current and previous years (three-year minimum) • all inputs used for current and previous years (three-year minimum) • field or paddock status (Organic, Transitional, Conventional) for previous years (three-year minimum) One of the realities of organic farming under the Federal Standard is the expected increase in the number of operations that feature both organic and conventional production. The terms split and parallel are commonly used to describe such farms (see Text Box 4B in this section). Many certifiers require that field histories and other records cover conventional as well as organic management on split and parallel op- erations. It is important that the OSP addresses all hazards of contamination and commingling that may arise. Prior to the development of the National Organic Program Standard, a number of certifiers re- quired that split operations have a long-term plan for full conversion to organic. There is no such re- quirement in the National Organic Program Regulations. 4.1 Have you completed your Organic System Plan (OSP) [§205.201(a)]? 4.2 Has your OSP been approved by your certifying agent(s) [§205.201(a)]? 4.3 Is your farm or ranch map complete and accurate? 4.4 Have you completed a field/rangeland history sheet? n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  14. 14. Revised February 2004 Page 14 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 4.5 Are the numbers/names used on your map consistent with those used on field histories and other records? 4.6 If your production unit features a number of pens for segregating livestock, are those pens permanently numbered? 4.7 Do you have a complete map of your production facility featuring pen num- bers? Notes on Organic System Plan V. Adjoining Land Use Organic livestock—as well as the crops they eat—must be protected from contamination by prohibited substances used on adjoining lands. The most common concerns are pesticide drift and fertilizer runoff. In recent years, pollen drift from genetically engineered crops has also become an issue. See Text Box 5A in this section of the workbook. Contamination prevention for organic systems usually requires a multi-pronged approach. Strategies may include one or more of the following: • isolation. Fields, farms, and ranches that are remote or are located at substantial distances from conventional production, roadside spraying, or industrial uses are considered to be ad- equately protected. • barriers. Hedges and woods serve as barriers to air- and water-borne contaminants. • buffer zones. It is common practice for organic producers to designate a buffer zone along borders or property lines where adjoining land and livestock are conventionally managed. Crops harvested from buffer zones, even though organically grown, must be treated as con- ventional. Organic livestock may not graze buffer areas and may not be fed buffer zone crops. • drainage diversion • posting of property (for example, signage reading “Organic Farm: Do Not Spray,” etc.)20 n/a Yes No n/a Yes No n/a Yes No
  15. 15. Revised February 2004 Page 15 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • formal notification. Written notification is provided to neighbors, utilities, and authorities that manage adjoining lands and rights-of-way requesting cooperation to reduce contamina- tion. You may need to assume responsibility for weed control on roadsides and rights-of-way as part of any resulting agreement. Copies of formal notification letters must be kept on file.21 • verification of adjoining land use. A signed statement by the owner or manager of adjoining land serves as acceptable documentation.22 The use of buffer zones has a long history in certified organic production. Traditionally, such buffers were defined by width only, with 25 feet being the common distance specified in most certifier stan- dards. The National Organic Program Standard does not specify the required width for a buffer zone, it speaks only to the need to minimize contamination. Therefore, the width (and height, in some instances) of buffers may need to be adjusted for individual circumstances, for example, a more significant buffer is needed where adjacent land is sprayed by plane or helicopter. If your certifier suspects that your pastures or feed crops are contaminated, residue testing may be re- quired. If residue levels exceed 5% of the EPA tolerance levels, the feed can no longer be considered organic [§205.671]. Note that residue testing is not an accepted substitute for buffer zones or other strat- egies to prevent contamination. It can, however, serve as an indicator that those strategies are effective. . Text Box 5A Genetic Engineering (GE) and Genetically Modified Organisms (GMOs) Genetic engineering is considered an excluded method in the National Standard. §205.2 defines ex- cluded methods as a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology). Such methods do not include the use of traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture. Genetic engineering is a new feature of the agricultural landscape, and the organic community is still coming to grips with it. Clearly, organic producers are not allowed to market genetically engineered animals as organic, and genetically engineered biopesticides, probiotics, medications, and the like may not be used in organic production. Organic livestock feed may not be derived from GE crops. Since genetically engineered crops are not allowed in organic crop production, organic feed, ostensi- bly at least, is non-GMO by default. However, there is a danger of GMO contamination of organic feed crops. At the time of this writing there are no genetically engineered forage crops on the market, so pasture-based production is not unduly affected. Organic grains—especially corn—are the most heavily contaminated. While this has become a serious issue in export of organic food grain products, it is not a top-drawer concern with respect to domestic organic livestock feed at the present. That may change in the future and producers should be aware of it. If you grow grain crops as organic feed, you must take steps to prevent contamination. Guidelines for preventing genetic drift from GM crops to organic fields are being evaluated.
  16. 16. Revised February 2004 Page 16 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 5.1 Are all fields and paddocks well isolated or provided with buffers to prevent contamination [§205.202(c)]? 5.2 If there is danger of contamination from adjoining land use, are you taking steps to minimize the risk [§205.202(c)]? 5.3 Have you notified your certifier(s) of any drift or misapplications of pro- hibitedsubstances to any field, production unit, site, facility, livestock, or product that is part of the organic operation [§205.400(f)(1)]? If serious drift contamination occurs, you should also contact your State Department of Agriculture, which has (or should have) the responsibility to follow up on such matters.23 5.4 Have you consulted your certifier to learn if there are specific requirements for buffer zones or other matters relating to adjoining land use? Notes on Adjoining Land Use VI. Supporting BioDiversity The National Organic Standard defines organic production as a production system that “respond(s) to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity” [§205.2]. Aside from an additional mention of “biological diversity” in the definition of crop rotation, the practice standards do little to highlight biodiversity as something to be measured and monitored. n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  17. 17. Revised February 2004 Page 17 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Biodiversity is a principle of sustainable agriculture and an important indicator of a healthy organic farm or ranch.24 It plays a particularly crucial role in insect pest management. Diverse agricultural systems support strong populations of predators and parasites that keep pest populations at manageable levels. Pasture-based livestock systems, and those based on mixed crop and livestock production, possess the basic elements for developing a sound diverse agroecosystem. Specialized production systems with limited land base will have a more difficult time designing their systems to support biodiversity. One of the more common means through which farmers and ranchers promote biodiversity is by estab- lishing and maintaining forage diversity in their pastures and range. One of the more interesting varia- tions on this concept found in humid regions is herbal pastures or leys. Herbal pasturing differs sharply from the conventional notion that a productive pasture must feature only one or two useful forage plant species. Herbal pastures contain a number of non-traditional forage species and plants, many of which would be considered weeds in conventional systems. The majority of these plants—such as forage chicory—are broad-leaved, tap-rooted plants (sometimes referred to as forbs) that provide diverse nutri- tion to the livestock, capture and recycle nutrients from the subsoil, and draw beneficial insects to the field. A diversity of plant species also stabilizes the pasture ecosystem against environmental stress. If one or more of the forage species is wiped out by drought, disease, over-grazing, or another factor, the remaining species survive to ensure a source of feed and protect the soil.25 Properly grazed and managed pastures become increasingly biodiverse on their own. This is the natural process of succession as it would occur in a prairie environment grazed by buffalo or other wild herbi- vores. In mixed crop and livestock systems—where pasture and forage crops are grown as well as grains— strategies for biodiversity include crop rotation26 and the use of cover crops.27 Organic producers who manage such systems also seek to reduce the frequency of tillage to aid in conserving the diversity of soil organisms.28 A diversity strategy that is drawing increased attention is agroforestry. Agroforestry is the integration of tree crops with livestock or crop production. The term silvopasture specifically describes agroforestry systems that combine grazing with tree farming.29 Further means by which organic livestock producers promote biodiversity include: • multi-species grazing30 • limiting the use of botanicals and other natural-but-broad-spectrum pesticides • introducing beneficial organisms in the form of soil or compost inoculants, as beneficial preda- tors and parasites, or as pollinators • establishing habitats for beneficial insects and wildlife31 • adjusting the timing and frequency of mowing and grazing to accommodate nesting birds and other wildlife • providing roosting, nesting, or sheltering structures such as bird or bat houses • diversification of farm enterprises 6.1 If you produce both livestock and crops, have you implemented a crop rotation that integrates your enterprises effectively with good nutrient cycling and pest management? §205.205 of the Regulations requires that crop rotation be used whenever annual crops are produced organically. 6.2 Are you providing non-crop areas as habitat for beneficial insects and wildlife? n/a Yes No n/a Yes No
  18. 18. Revised February 2004 Page 18 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 6.3 Have you considered adding more enterprises to your operation? Notes on Biodiversity VII. Organic Soil Management for Pasture and Hay Crops The discussion provided here is brief and does not make clear how fundamentally important soil management is to a working organic system. There are many excellent books on the subject, but to get a good perspective, see ATTRA’s Sustainable Soil Management at <> and the University of California publications Soil Manage- ment and Soil Quality for Organic Crops at <> and Soil Fertility Management for Or- ganic Crops at <>. Organic agriculture is built around the notion that providing nutritious food and feed is the best way to improve and sustain the health of people and livestock, and that the best way to grow nutritious food is by emulating nature, which begins with feeding the organisms of the soil. Soil micro-and macro-organ- isms are the external digestive system that processes organic matter, delivering a smorgasbord of miner- als, vitamins, and other nutrients to the crop at a metered pace. This is in contrast to the conventional approach where crops are flooded with a limited number of soluble fertilizer nutrients, leading to “luxury consumption,” imbalanced plant nutrition, and a susceptibility to disease and attack by insect pests. The food that soil organisms need to do their job comes in the form of organic matter. Thus composting, manuring, green manuring, and similar activities are the standard practices of organic crop production. Good rotational grazing management provides comparable humus development, through the slough- ing-off of roots when plants are grazed or mowed, and through the natural deposition of manures. In addition, since there is little-to-no tillage, humus accumulation is encouraged. Nitrogen is the limiting nutrient on most organic farms. The most economical source of nitrogen is from legumes. Biological nitrogen fixation in legumes results from a symbiotic relationship between the plant and rhizobium bacteria. Rhizobium bacteria “infect” the roots of legumes, forming nodules. The bacte- n/a Yes No
  19. 19. Revised February 2004 Page 19 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices ria then fix nitrogen from the air as proteins, which are shared with the legume host and adjacent plants. In organic grain production, forage legumes are included in rotations because they fix enough nitrogen to supply the needs of one or more subsequent seasons of non-leguminous crops. In pasture-based systems, legumes are commonly intercropped with grasses, to provide them with nitrogen. In humid regions many producers adjust liming and fertilization to meet the needs of the legumes in their forage mixes. Thus, legumes become the primary source of nitrogen to drive the system; additional manures and other organic fertilizers may then be applied according to the need for other nutrients like phosphate and potash. This reduces the problem of soil nutrient overloading that frequently occurs when farms import and apply large quantities of manure over many years. The inoculation of legume seed may be necessary to optimize nitrogen fixation. If you have observed good nodulation on the same legume crop in the last three to five years, re-inoculation may not be neces- sary. If inoculation is required, rhizobium inoculant can be purchased for this purpose. Be certain you are requesting an inoculant appropriate to the kind of legume you are planting. Also, be certain that you specify a rhizobium product that does not contain genetically engineered material. Organic growers have also learned the value of providing additional mineral nutrition—commonly in the form of lime, gypsum, and other rock powders—where nutrient deficiencies are not fully addressed by humus building practices. In circumstances where specific micronutrient deficiencies are found, cer- tain forms of synthetic micronutrients may even be used. When synthetic micronutrients are applied, their use must be justified to the certifier. A soil test or audit is the most common means of determining and documenting that a deficiency exists. Note that this requirement for testing does not apply to mate- rials that are naturally rich in a spectrum of micronutrients (glacial gravel dust, greensand, kelp meal, etc.), though soil auditing is still advisable in guiding their use. The organic community is divided as to what constitutes a good soil test and good soil test recommenda- tions. There is general consensus that, at the very least, the primary nutrients phosphorus and potash, pH, and organic matter should be monitored, though additional specific testing is required to identify micronutrient deficiencies. There is a growing segment of organic producers—especially livestock pro- ducers—that feels a good analysis must include cation exchange capacity and cation base saturation; that lime and potash recommendations will not be accurate without them, and that animal health weighs in the balance.32 A degree of perspective is required when managing organic soil fertility. Many of the inputs organic market farmers might employ (seed meals, kelp meal, fish emulsion, etc.) are not likely to be economical for fertilizing most forages. New producers should not become confused and think that such costly materials are necessary and should not fall into the “input substitution” trap. Examples of practical and cost-effective tools and strategies are provided in the questions that accompany this section. Still, many farm and ranch operations will need or benefit from some purchased “natural” fertilizers and amend- ments, especially during transition. With time, however, well-designed organic systems become pro- gressively more self-reliant and require fewer off-farm inputs. This is true of all organic systems, but especially true of livestock systems, where manure recycling works to close the loop of nutrient supply and demand. Another factor that is not often discussed when it comes to organic soil management is compaction. Compaction can occur on the soil surface and is evident as crusting; it can also occur as a sub-surface problem and is often called plowpan. In cropping systems, compaction is usually a symptom of excessive tillage or field operations that were done when the soil was too wet. In pastures, compaction can also be caused by grazing or field operations when the soil is too wet. It is appropriate for graziers to tempo- rarily confine livestock when pasturing can lead to excessive soil compaction.
  20. 20. Revised February 2004 Page 20 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.1 Have you taken the time to learn about your soil resource? Do you know its classification(s)? Erodability potential? Have you studied NRCS soil maps? 7.2 Do you test your soils on a regular basis? 7.3 Do you keep your current and past soil test results on file and use them to monitor the effects of your farming practices? 7.4 Do you make fertility management decisions based on soil test, tissue test, or other nutrient test results [§205.601(j)(6)]?33 Remember, application of concentrated micronutrients (sulfates, chelates, etc.) may be made only if the need is documented by soil or tissue tests. 7.5 Is there little or no evidence that your forage yield or quality suffers due to soil fertility problems? 7.6 Do you use approved cultural practices and materials to maintain or im- prove soil organic matter/humus content [§205.205(a) and §205.203]? Al- lowed practices and materials typically include but are not limited to the following: • rotational grazing and other forms of good grazing management • animal manures34 , composts, or other organic fertilizers35 • crop rotation (in mixed crop and livestock systems)36 • cover crops and green manures (in mixed crop and livestock systems)37 • minimizing tillage and length of time that soil remains bare • esoteric practices (See Text Box 7A) n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No Text Box 7A What Are Esoteric Practices? Esoteric practices are metaphysical methods for crop management and animal health that are not generally accepted in the conventional scientific community, nor are they easily explained using common scientific terminology. Those esoteric practices that are often applied to soil and plant management include radionics, dowsing, the use of biodynamic preparations, and astrological plant- ing. Most esoteric practices are allowed in organic production.38
  21. 21. Revised February 2004 Page 21 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.7 Do you use approved cultural practices and materials to manage soil fertility and crop nutrition [§205.205(c) and §205.203]? Allowed practices and materials typically include but are not limited to the following: • use of deep-rooted forage species to capture nutrients from the subsoil • use of catch crops in mixed crop and livestock systems39 • rock mineral fertilizers and amendments40 • use of mineral-rich organic fertilizers, manures, and/or composts41 • foliar fertilization42 • esoteric practices (see Text Box 7A) 7.8 Do you use approved cultural practices and materials to provide nitrogen to your forages [§205.205(c) and §205.203]? Allowed practices and materials typically include but are not limited to the following: • forage legumes in hay/pasture43 • rhizobial inoculation of legume seed • legumes in rotation in mixed crop and livestock systems44 • livestock manures or composts45 • N-rich organic fertilizers46 7.9 Do you use approved cultural practices and materials to conserve soil and water [§205.205(d) and §205.203]? Allowed practices typically include but are not limited to the following: • avoiding over- and under-grazing (See Text Box 7B) • controlling livestock access to riparian areas • appropriate conservation structures such as buffers, grass waterways, and terraces • contour cultivation and strip cropping in mixed crop and livestock systems • cover crops and conservation tillage in mixed crop and livestock systems 7.10 Are you making best use of the available solar energy that reaches your farm or ranch (see Text Box 7B)? Allowed practices that optimize the capture of solar energy include but are not limited to: • interseeding/overseeding annual forages • leaving enough forage height for rapid re-growth47 • selecting forage varieties best-adapted to your region • maintaining a diversity of forages, for example, warm- and cool-season grasses, legumes, and forbs, etc. • silvopasture n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  22. 22. Revised February 2004 Page 22 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Text Box 7B Grazing as Solar Agriculture All agriculture ultimately runs on the energy of the sun. It may be the sunlight captured today in a growing crop through photosynthesis, or it may be the sunlight captured eons ago by primitive plants and stored as oil, coal, or natural gas—and eventually converted to nitrogen fertilizer, pesti- cides, and tractor fuel. Conventional agriculture is driven by reliance on the stored solar energy in fossil fuels, causing environmental problems, increasing the vulnerability of the food system, and spending the inheritance of future generations. Organic agriculture works to reverse the energy equation—reducing reliance on petroleum and focusing on the use of ambient renewable solar en- ergy. In contrast to systems that rely primarily on grain and mechanically harvested forages, pasture- based production is certainly much more solar-driven. Far less fuel is consumed by letting animals do their own harvesting and manure-spreading, and pasture-based production generally requires less imported fertilizer—much of which is energy intensive. The challenge for the grazier is to optimize the capture of solar energy. This is exemplified through management strategies that support densely growing forage that wastes little-to-no sunlight on bare ground. It involves selecting forage species that keep pastures green for as long as possible through- out the year. It also involves optimizing the use of legumes to fix nitrogen and deep-rooted broadleaves to extract subsoil minerals as a means of reducing outside fertilizer needs. Like all forms of organic farming, good organic grazing is very management intensive. In fact, what is popularly called management intensive grazing (MIG) or rotational grazing is well suited to organic systems. Fortunately, many good sources of information are available.48 7.11 Do you use allowed fertilizers and soil amendments (see Text Box 7C in this section) [§205.105 and §205.203]? Allowed fertilizers and amendments typically include but are not limited to the following:49 • rock dusts; includes most mined minerals, such as aglime50 • animal by-products • livestock manures • composts • plant materials and extracts • marine products and by-products • microbial inoculants and enzymes • natural soluble fertilizers with restrictions: υ potassium chloride (muriate of potash): allowed only if it is derived from a mined source and is applied in a manner that precludes buildup of chlorides in the soil [§205.602(g)]. Note that most commercial sources of potassium chloride are synthetic and NOT allowed in organic production. υ sodium nitrate (Chilean nitrate): allowed only if its use con- stitutes no more than 20% of the crop’s total nitrogen re- quirement [§205.602(h)]. n/a Yes No
  23. 23. Revised February 2004 Page 23 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Prohibited fertilizers and amendments include but are not limited to the following: x most synthetic or “artificial” commercial fertilizers, such as anhydrous ammonia, urea, ammonium nitrate, superphosphate, ammoniated phosphates, calcium nitrate, etc. [§205.105(a)] x biosolids; also known as municipal waste, sewage sludge [§205.105(g)] x most industrial by-products, especially if contaminated with heavy metals [§205.203(d)] x ash from manure burning [§205.602(a)] 7.12 Do you keep records of all fertilizer and amendment purchases, along with product labels? 7.13 If you are applying manure, compost, or another acceptable fertilizer or amendment, are you taking care to avoid contamination of surface and groundwater [§205.203(c)]?52 Text Box 7C What Inputs Can I Use On Organic Pastures and Range? One of the greater difficulties that organic producers face on a regular basis is determining whether or not a particular product or material may be used in organic production. Sad to say, the problems are real, but some basic clarifications will help. First of all, all natural or nonsynthetic materials can be assumed to be acceptable in organic production. There are a few exceptions, however, which will be explained shortly. Most organic producers and prospective producers have heard about the National List. The National List comprises §§205.600-205.619 of the National Standard; §205.601 and §205.602 are those sections directly pertinent to crop production, which includes forages. §205.601 includes synthetic materials allowed in organic crop production—for example, sulfur, insecticidal soap, etc.; §205.602 addresses natural, or nonsynthetic, materials that are prohibited, for example, ash from manure burning, nico- tine sulfate, etc. When considering commercial products, it is important that the grower be aware of all ingredients to determine that none are prohibited. If a full disclosure of ingredients is not found on the label, details should be obtained from the distributor or manufacturer and kept in the grower’s files. Note that such details should extend to inert ingredients. When in doubt about the acceptability of any material or product for certified organic production, contact your certifier. An important organization to know about is the Organic Materials Review Institute (OMRI).51 OMRI is a non-profit organization that evaluates products for suitability in organic production and process- ing. OMRI does not have status as a regulatory body. However, its decisions with regard to the acceptability of commercial products are highly respected and accepted by most certifiers. OMRI Listed products can be purchased and used with a high degree of confidence. Producers should be aware, however, that there are many acceptable products in the marketplace that have not been evalu- ated by OMRI and do not carry the OMRI Listed seal. Again, it is important to contact your certifier to verify whether a particular product or material can be used. n/a Yes No n/a Yes No
  24. 24. Revised February 2004 Page 24 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.14 If both organic and conventional pastures and crops are fertigated using the same equipment, are you taking steps to ensure that prohibited fertil- izer materials do not contaminate organic crops? It is a bad idea to irrigate organic crops with the same equipment used for conventional fertigation. However, any certifier that permits dual use will most likely insist on pro- tocols that include thorough cleaning and flushing, plus a date log for all cleanouts and irrigations. 7.15 Do you rotate feeding areas on your pastures? Using the same spot to feed hay or concentrated feeds results in manure accumulation in one place. This increases the hazard of nutrient pollution via run-off and leaching. It also leads to a fertility imbalance in the soil at the feeding site. Feeding hay on a permanent pad to collect manure is an alternative to site rotation. Notes on Organic Soil Management VIII. Weed Management in Pasture and Hay Crops Weeds are generally considered the greatest challenge to growing organic crops, whether they be veg- etables, grains, orchard trees, or pastures. The conventional farmer or rancher typically responds to weeds by spraying them with synthetic herbicides. Organic graziers do not have this option. If they are good managers, most will admit they really don’t need it, either. When good grazing practices are used, along with good soil fertility management, weeds become a minor issue. Forage species gradually crowd out most weeds, and any that remain are “grazed off” along with the more desirable plants. Beyond this, specific control measures are required only on an occasional basis. Most organic growers understand that many weeds occur simply because agricultural soil is left uncov- ered or unoccupied. 53 In pasture and range systems, bare soil commonly results from over-grazing. It can also result from undergrazing. Undergrazing encourages individual plants to become overly-ma- ture, dominating space and “shading out” emerging seedling grasses, legumes, and forbs. Mature plants n/a Yes No n/a Yes No
  25. 25. Revised February 2004 Page 25 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices are not stimulated to produce fresh growth, and nutritional quality plummets (see Text Box 15A of this workbook). When these overgrown plants are grazed or mechanically clipped, large areas of bare soil are exposed between plants—providing an excellent toehold for weeds. Grazing practices that maintain a dense stand of forage plants in their vegetative state (by not allowing them to go to seed) control many of the problem weeds that graziers are known to struggle with.54 One strategy that good graziers use to manage weeds that “escape” intensive grazing is multispecies graz- ing. For example, cattle typically do not eat woody plants; therefore goats—run alongside or in rotation with cattle—provide an excellent weed control complement. Sheep relish forbs that cattle may find unpalatable, and will clean up pastures that would otherwise require clipping.55 Organic producers also know that many weeds prosper under certain soil fertility conditions. Many weeds in the humid east are encouraged on low pH or low calcium soils.56 Liming to adjust pH and provide the correct balance of calcium and magnesium can often reduce pressure from certain weeds (for more details, see Section VII of this workbook). At the same time, fertilization can increase weed pressure. Applying large quantities of manure to the land frequently increases weeds, at least in the short term. In many such instances, the cause can be traced to weed seeds present in bedding materials. In others, however, raw manures have a stimulating effect on weed seeds already present in the soil. There are always fallback tools available when creative management either doesn’t succeed or is undone by weather or some other unexpected problem. Mowing, bushhogging, or selective hand-cutting are commonly relied upon; flame weeding or spraying with allowed herbicides may also be done. Even though a few “natural” herbicide products are now available, most are expensive, are restricted in their use, and seldom provide the same results as synthetic herbicides. Taking the big picture view of organic production, natural herbicides may be useful tools, but extensive reliance on them for weed management is inconsistent with traditional organic thinking and also contributes to producer reliance on off-farm inputs. The National Standard encourages reliance on whole system effects before employing specific practices or materials. See Text Box 8A for details on how weed control decisions must be made. A few words should also be said about weed management in mixed crop and livestock systems. A good humus-building rotation is one of the first steps to effective weed management in pastures and hay crops, as well as in row crops. A diverse rotation also reduces the number of niches that problem weeds can exploit from year to year.57 Sanitation is among the most under-recognized of good organic practices. Cleaning harvesting and mow- ing equipment between fields can prevent the distribution of weed seeds onto previously clean areas. Mowing or flaming ditchbanks and other areas adjacent to the field can work to prevent weed infesta- tion. However, because these areas can often serve as habitat for wildlife and beneficial insects, the timing of mowing and other operations should be carefully chosen.58 It is important that weeds not go to seed. Most weed species are capable of producing vast numbers of seeds that can create problems for years to come. There is growing evidence that biologically active soil—such as that encouraged under organic management—has an abundance of organisms that natu- rally reduce weed seed populations. However, this bonus of an organic system will not bail out bad management that allows annual reseeding of weeds.
  26. 26. Revised February 2004 Page 26 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Text Box 8A Weed and Pest Management Decisions §205.206—the Crop pest, weed, and disease management practice standard—requires that produc- ers use a three-level hierarchical approach in deciding how to deal with these problems. This can most easily be explained by designating these levels A, B, and C. Level A: The first line of defense in managing weed, insect, and disease pests generally comprises the most sustainable and systems-based practices. It emphasizes the fact that a well-designed and healthy organic system will naturally have fewer pest problems. Level A practices specifically include: • crop rotation and nutrient management [§205.206(a)(1)] • sanitation measures to remove disease vectors, weed seeds, etc. [§205.206(a)(2)] • cultural practices such as resistant or tolerant varieties, timing of planting, etc. [§205.206(a)(3)] Level B: Level B is the second line of defense, to be chosen if the basic systemic practices of level A are not sufficient to control the weed, insect, or disease problem. Level B practices generally include mechanical and physical practices that are traditional in organics, and the use of nonsynthetic or “natural” materials. Level B weed control options include: • mulching with fully biodegradable materials [§205.206(c)(1)] • mowing [§205.206(c)(2)] • grazing [§205.206(c)(3)] • cultivation and hand weeding [§205.206(c)(4)] • flame, heat, or electrical weeding [§205.206(c)(5)] • plastic mulches [§205.206(c)(6)] Level B insect/animal pest control options include: • introducing or augmenting predators and parasites [§205.206(b)(1)] • developing habitat for beneficial predators and parasites [§205.206(c)(2)] • nonsynthetic lures, traps, and repellents [§205.206(c)(3)] Level B crop disease control options include: • management practices (for example, fire, flooding) [§205.206(d)(1)] • application of nonsynthetic biological, botanical, or mineral inputs [§205.206(d)(2)] Level C: Level C is the third line of defense, to be chosen if the level of pest control required is not achieved after A and B control options are applied [§205.206(e)]. In such instances, you are allowed the wider use of biologicals and botanicals to control pests. You also have the option to use those materials included on the National List under §205.601—Synthetic substances allowed for use in organic crop production. If you anticipate the need for level C control measures, be sure that you indicate this in your OSP. Be specific about the control materials you might be using. Outline the indicators or thresholds you monitor that will trigger the use of those materials.
  27. 27. Revised February 2004 Page 27 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 8.1 Does your production system keep weeds at manageable levels? 8.2 Do you use approved practices or materials to control weeds [§205.206]? Allowed practices and materials typically include but are not limited to the following: • rotational grazing • grazing in a timely manner • multi-species grazing • competitive forage types and varieties • adjusting soil fertility, pH, etc. • interseeding/overseeding • higher seeding rates • mowing/bushhogging • allowed herbicides • flaming59 • hand weeding or chopping • machinery sanitation to prevent the spread of weed seed and rhizomes • release of biological control agents60 • use of crop rotation, nurse crops, smother crops, and cultivation in mixed forage and row-crop production systems • esoteric practices (See Text Box 7A) Prohibited materials typically include but are not limited to the following: x most synthetic herbicides [§205.105(a)] x heavy metal herbicides x soap-based herbicides—these may only be used in non-crop areas of an organic farm [§205.601(b)(1)] x micronutrient-based herbicides [§205.601(j)(6) Notes on Weed Management n/a Yes No n/a Yes No
  28. 28. Revised February 2004 Page 28 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices IX. Pest and Disease Management in Pasture and Hay Crops Pests and diseases play a vital role in natural selection by removing sick and unthrifty plants. Organic proponents argue that sickness in plants can be traced largely to poor nutrition and other stresses that result from poor crop and soil management.61 Organic producers maintain that organic soil-building practices will produce crops that are properly nourished and thereby less susceptible to attack by pests and diseases. Furthermore, organic producers and ecologists agree that natural biological pest control arises in a healthy organic system in the form of an active complex of natural predators and parasites that suppress pest populations. In actual practice, most managers of organic pasture and range rarely take additional action to control insect and disease pests. Where organic forages are concerned, maintaining a biodiverse ecosystem and using good fertility and cultural practices naturally keep pests and diseases from becoming a manage- ment problem. In such systems, pests are not eliminated but damage levels are low enough to be toler- ated. There are exceptions, of course—grasshopper plagues in the West and armyworm invasions in humid climes are good examples of circumstances where more pest control may be required.62 High-value organic hay crops can also have special pest problems. Alfalfa weevil is a good example of a pest that may well require additional attention.63 Insect and disease pest management is addressed in considerable detail in NCAT’s Organic Crops Workbook; it contains information that is not duplicated here.64 The National Organic Standard requires that pest management decisions be made in a hierarchical fash- ion. See Text Box 8A in Section 8 for details on how pest and disease control decisions must be made in organic systems. 9.1 Does your production system keep disease and insect pests at manageable levels? 9.2 Do you use approved practices to control plant disease and insect pests [§205.206]? Allowed practices typically include but are not limited to the following: • Integrated Pest Management (IPM) monitoring65 • animal predators (birds, bats, ducks, guinea fowl, etc.) • establishing and maintaining beneficial insect and wildlife habitats66 • resistant and tolerant crop varieties • sanitation • burning • crop rotation • flaming • mass trapping of insect pests • release of beneficial insects67 • application of allowed pesticides • esoteric practices (See Text Box 7A) n/a Yes No n/a Yes No
  29. 29. Revised February 2004 Page 29 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 9.3 Do you use allowed insect pest and disease control materials to manage forage pests [§205.206]? Allowed inputs typically include but are not limited to the following:68 • beneficial insects and other organisms69 • biological pesticides70 • botanical pesticides71 • insecticidal soaps72 • mineral-based pesticides • pheromones Prohibited pest and disease control materials include but are not limited to the following: x most synthetic insecticides, fungicides, miticides, etc. [§205.105(a)] x heavy metal-based pesticides x synthetic wetting agents [§205.105(a)] x nicotine sulfate and other tobacco products [§205.602(f)] x strychnine [§205.602(e)] 9.4 Do you keep records of all pest and disease control materials used, along with the product labels? 9.5 If you apply natural pesticides, do you do so in a manner that minimizes risk to non-target organisms and aquatic systems? Notes on Insect and Disease Pest Management X. Seeds and Planting Stock An entire section of the Federal Regulations—§205.204—addresses seeds and planting stock in organic production. This section is as applicable to hay and pasture crops as it is to vegetables and row crops. The first basic rule is this: organic seeds and planting stock MUST be used for organic production.73 When an equivalent organic crop variety is not commercially available, untreated conventionally grown seeds and planting stock may be used. See Text Box 10A for an explanation of planting stock; for clarifi- cation of equivalency and commercial availability, see Text Box 10B. n/a Yes No n/a Yes No n/a Yes No
  30. 30. Revised February 2004 Page 30 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The second basic rule is one that has little relevance to forage systems, but needs to be mentioned any- way. It relates to annual transplants, which MUST be organically grown for organic production.74 The third basic rule is: seeds, annual seedlings, and planting stock used in organic production may NOT be treated with prohibited substances. There is one exception. Treatment with prohibited substances is allowed when the application of those substances is a requirement of Federal or State phytosanitary regulations [§205.204(a)(5)]. Conventional seed treatments are usually fungicidal; most fungicides used for this purpose are prohib- ited in organic production. Allowed treatments include natural materials—such as biological inocu- lants—and synthetic substances that are on the National List—such as seaweed extracts. The most com- mon example of allowed seed treatment is the inoculation of legume seeds with rhizobium bacteria. Since some rhizobium products can be genetically engineered or contain GE ingredients, it is important to make that determination in advance and obtain an allowed product. Organic growers must make certain that the seeds, transplants, and planting stock they use are not ge- netically engineered. Purchasing these items from a certified organic producer should guarantee that the propagation materials are not genetically modified and have a minimal degree of GMO pollen contami- nation. There is a particular provision in the Seeds and Planting Stock standard that may be relevant to you, especially if you establish or interplant any of your fields with perennial planting stock. Examples of perennial planting stock include grass sprigs, root pieces, and tree seedlings. §205.204(a)(4) reads “[n]onorganically produced planting stock to be used to produce a perennial crop may be sold, labeled, or rep- resented as organically produced only after the plant- ing stock has been maintained under a system of organic management for a period of no less than 1 year…” The popular interpretation of this section has been that pe- rennial planting stock may be obtained from nonorganic sources, but it must be under organic management for twelve months before the first harvest of an organic crop. This interpretation is consistent with many organic cer- tifier standards prior to federal regulation. If you read this provision carefully, however, it suggests an alter- nate interpretation. The alternative interpretation is that the twelve-month requirement applies to the sale of pe- rennial planting stock, not to its use once it has been placed in production. In other words, it is possible that this provision is pertinent to nursery production and not to the production of fruits, nuts, produce, or forage. The way your certifier chooses to interpret §205.204(a)(4) of the Standard can have implications if you are estab- lishing a Bermuda grass pasture, interplanting comfrey as a forage plant, or establishing an agroforestry sys- tem—especially one with forage trees such as locust. In many of these examples, there is a lag time of one year or more to allow for establishment, which removes much of the concern. However, the question of whether you Text 10A About Planting Stock The National Organic Standard lumps plant propagation materials into three ba- sic categories: seeds, annual seedlings, and planting stock. Seeds is self-explanatory. Annual transplants are seedlings of annual crops that have been removed from their original place of production and replanted elsewhere [§205.2]. Planting stock is defined as “[a]ny plant or plant tissue other than annual seedlings but including rhizomes, shoots, leaf or stem cuttings, roots, or tu- bers, used in plant production or propaga- tion [§205.2].” The most likely example of planting stock you might use in pasture or hay production is sprigs. Sprigs are clumps of stolons or rhizomes that are used to veg- etatively propagate certain grasses—espe- cially some warm-season species like Ber- muda grass.
  31. 31. Revised February 2004 Page 31 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices need to seek an organic source for perennial planting stock and document that search remains. Be certain to contact your certifier in advance of purchasing perennial planting stock to learn in full detail what your constraints might be. 10.1 Is all seed used either: • organically produced and/or • conventionally produced, non-GMO seeds that have NOT been treated with prohibited substances [§205.204(a)]? 10.2 Are only NON-genetically engineered seeds and planting stock used [§205.105(e)]? 10.3 If seeds and sprigs are produced on-farm, are they grown using organic methods and approved inputs [§205.204(a)]? 10.4 Where pasture is being established using perennial planting stock, such as sprigs, have you determined what your certifier requires with regard to sourcing [§205.204(a)(4)]? Text Box 10B Equivalency and Commercial Availability Equivalent variety is generally understood to mean a cultivar of the same type and similar plant characteristics when compared to the original preferred variety. For these purposes, type refers to the basic plant type (for example, there is a type of soybean called a haybean that is harvested as a forage. This is different from the standard food type and feed type of soybean that most farmers are familiar with); characteristics refers to factors such as color, pest resistance, and maturation. According to the National Organic Standard, an equivalent variety of seed or planting stock would be considered commercially unavailable if you could not locate an organic supplier. It might also be considered commercially unavailable if the organic supplier could not provide you with the quan- tity of seed you need, or if the available seed quality is substandard. Factors that might make seed quality substandard include the presence of seed-borne disease, very low germination percentages, high noxious weed seed content, and the like. The higher cost of organic seed and propagation materials is NOT considered an acceptable reason for using nonorganic seed or planting stock. Ultimately, the certifier must make the final decision on whether the use of nonorganic seed or planting stock is justified. You will need to present ample documentation to support any use of nonorganic seed, including a record of your attempts to locate organic seed sources. This usually entails making a record of phone calls, letters, or e-mails to and from seed suppliers documenting attempts to find an organic source. Most certifiers want clear indication that you have contacted at least three suitable suppliers.75 n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  32. 32. Revised February 2004 Page 32 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 10.5 Do you retain documentation of all seeds, seed treatments (including rhizobial inoculants), and planting stock purchases? 10.6 Do you keep seed tags and empty packets on file? 10.7 If seed or plant treatments are used, have you determined that they are allowed and not genetically modified [§205.105(e)]? It is advisable to re- tain all documentation that proves a substance is allowable in organic pro- duction. Notes on Seed and Planting Stock XI. Field Equipment Equipment used for pasture management and for hay production and hauling must not be a source of contamination or a means by which organic and conventional products are commingled. 11.1 If harvesting, hauling, and crop handling equipment is also used for conventional crops, are cleanout protocols established and cleanout logs maintained? 11.2 If split or parallel production is done, is separate spraying equipment designated and clearly marked? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  33. 33. Revised February 2004 Page 33 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 11.3 If sprayers, planters, or dry material applicators are also used to apply prohibited materials for conventional production, are cleanout protocols clearly established and cleanout logs maintained? When seed planters are equipped with insecticide or fertilizer boxes and tanks that are NOT used for organic production, many certifiers prefer that these be removed or that the drive chains be disconnected when operating on organic acreage. 11.4 Are your sprayers, applicators, and spreaders properly calibrated to ensure precise application of materials? 11.5 Are your tractors, trucks, and other equipment free of fuel, coolant, and lubricant leaks? 11.6 Are all internal combustion engines properly tuned and maintained to ensure optimal fuel efficiency and reduce air pollution? 11.7 Is routine engine cleaning and maintenance of equipment done where it cannot contaminate production fields, harvested crops, or feeds? 11.8 Are fuels, lubricants, paints, coolants, and the empty containers that held these fluids stored where they cannot contaminate harvested crops? 11.9 Do you avoid field operations when soils are wet to prevent excess compaction and damage to soil structure? Notes on Field Equipment n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  34. 34. Revised February 2004 Page 34 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XII. Hay and Haylage Harvest Conventional hay harvesting sometimes involves the use of materials that might not be accepted in or- ganic production. Some preservatives and mold inhibitors, for example, may be prohibited in organic production. Individual products should be checked to determine whether they are natural (nonsynthetic) or are listed as an allowed synthetic input (See §205.601 of the National Standard for the list of allowed synthetics). Use of fungicide-treated twine might be prohibited; check with your certifier. 12.1 Are you harvesting your forages at an optimum stage to ensure high feed quality and continued viability of the stand? This question concerns good overall management and is not related to organic certification. Many pro- ducers sacrifice forage quality for quantity by harvesting when the crop is too mature. 12.2 If harvest-aid products are used, are they approved for organic production [§205.105]? Notes on Hay and Haylage XIII. Monitoring Your Pasture’s Performance The following questions highlight several indicators that can help you determine how well your organic management system is functioning; they can be reviewed annually and used to monitor your progress. Also included are additional questions that address special environmental concerns. 13.1 Does your pasture consist predominantly of desirable, well-adapted legumes, forbs, and grasses? n/a Yes No n/a Yes No n/a Yes No
  35. 35. Revised February 2004 Page 35 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 13.2 Are your forages usually at or near their optimum quality when you graze or harvest them? It is undesirable (and unprofitable) for pasture species to become rank and overly mature. Over-mature plants are not only low-quality livestock feed, they tend to shade out new seedlings, particularly clover, leading ultimately to bare ground between plants. (See Text Box 15A in Section XV of this workbook.) 13.3 Are your pastures generally free of subsurface compaction?76 Unless the pasture is located in a natural wetland, standing water is often an indicator of subsurface compaction. 13.4 Are your organic matter/humus levels stable or increasing [§205.203(c)]?77 13.5 If used, are tillage operations becoming easier under organic management from year to year? 13.6 Are earthworms and earthworm burrows evident in the soil?78 There are some circumstances where earthworms will not be found, even in well managed soils. Soils that routinely flood in spring, very arid soils, and some heavily glaciated soils in the northern tier of states may not have earthworms. 13.7 Does your soil emit a rich, earthy smell when tilled or dug? 13.8 Is dung beetle activity evident?79 Dung beetle activity should be vigorous on well-managed, organic permanent pastures and range. Less activity will be seen on pastures that are part of a mixed crop rotation, because tillage disrupts the life cycle of this insect. However, dung beetles are mobile and should still be active on rotation pasture. Note: the synthetic worming agent, ivermectin—allowed in organic production on a limited and emergency basis—is especially harmful to dung beetles [§205.603(a)(12)]. Where native dung beetle populations have been wiped out, they may be replenished with commercially available species. 13.9 Are your forages free of nutrient deficiencies under average conditions? Symptoms of nutrient deficiencies include chlorosis (yellowing), other discolorations of the leaves and stems, stunted growth, and consistently low yields. 13.10 Are your livestock free of disease conditions caused by excess soil nitrogen? Problems that may be caused or worsened by excessive nitrogen fertilization include grass tetany,80 prussic acid poisoning,81 nitrate toxicity,82 and fescue toxicity in high-endophyte fescue.83 n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  36. 36. Revised February 2004 Page 36 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 13.11 Are your livestock free of disease conditions caused by deficiencies or im- balances of mineral nutrients? Some problems that may occur include grass tetany, which can be brought on by imbalances of magnesium and potas- sium as well as by excess nitrogen. 13.12 Is there an abundance of beneficial predatory and parasitic insects (lady bugs, lacewings, mantids, small wasps, etc.) under normal conditions? 13.13 Is erosion controlled on all your fields, paddocks, and access lanes [§205.203(a)]? 13.14 Are the riparian areas (stream banks) on your farm or ranch stabilized and protected?84 13.15 Are natural wetlands on your farm or ranch protected? 13.16 Are waterways on your farm or ranch protected from livestock and live- stock wastes [§205.239(c)]? It is a good idea to use fencing and water tanks to restrict stock from fouling natural streams. Notes on Pasture Performance XIV. The Organic Approach to Livestock Health The basic strategy to sustain livestock vitality in organic systems is the same as in crop production—that is, to identify and optimize those elements and conditions in nature that support health. Essentially, there are three elements that must be provided: optimum nutrition, low stress living conditions, and a reasonable level of biosecurity. There are a number of key ways in which these three elements are expressed in organic practice—especially in mixed production and pasture-based systems. These in- clude: n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
  37. 37. Revised February 2004 Page 37 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • Providing balanced nutrition. This is reflected in the National Organic Program Regulations requiring organic feed [§205.237(a)]. Just as organic proponents argue that organic food is healthier for people, they likewise maintain that organic feed is healthier for animals. In mixed crop and livestock systems, the requirement for crop rotation results in a rich diversity of feeds. Similarly, in organic pasture-based systems, the absence of synthetic nitrogen fertil- izers encourages the growing of legumes alongside grasses, and the absence of synthetic her- bicides allows the growth of mineral-rich forbs; these contribute to the diversity of livestock diet. Note that artificial feedstuffs like synthetic urea are explicitly prohibited in organic pro- duction because they are found to be unhealthy for the animals. • Restricting exposure to toxins. Restricting toxin exposure is another reason for requiring organic feed. Residual pesticides and their breakdown products are additional sources of stress on livestock health—particularly to the liver, kidneys, and other systems responsible for eliminating poisons. • Excluding performance enhancers. Synthetic hormones and antibiotics are not allowed in organic production [§205.238(c)(3) and §205.238(c)(1)]. They are viewed as food contaminants by the organic community, and there are concerns over the development of antibiotic- resistant pathogens. These inputs push livestock to unnatural performance levels and mask the effects of unhealthy production systems. • Providing healthy and “natural” living conditions. [§205.239(a)] Living conditions are espe- cially important to livestock health. Buildings and facilities that are overcrowded, unsani- tary, lacking in fresh air movement, or are otherwise stressful to animals invite disease and injury. Living conditions for livestock must: ! permit livestock to exercise and to exhibit natural behaviors ! allow access to the outdoors ! provide access to pasture for ruminants ! offer animals protection from severe weather ! be safe and sufficiently sanitary ! not cause pollution • Avoiding excessively stressful management practices. All forms of stress increase suscepti- bility to injury and disease. Good organic managers strive to limit stressful handling of ani- mals as much as possible. This also applies to physical alterations—castration, ear notching, beak trimming, branding, etc. See Section XVIII of this workbook for more information on physical alterations. • Preventive practices. Good organic livestock management also involves the use of standard preventive practices, including sanitation, vaccinations, feeding of probiotics, quarantine of sick and newly purchased animals, and other biosecurity precautions to prevent difficult pest and disease problems from infecting organic stock. Your OSP should reflect a holistic health management plan that uses these principles and measures as a foundation. You must also indicate what practices, procedures, and materials will be used to deal with those animals that do become ill. These options are discussed in Section XIX of this workbook, “Treat- ment of Sick or Injured Livestock.” Finally, one aspect of organic animal health seldom discussed is the relationship between type and breed of livestock and its suitability for organic production in given climates and circumstances. The National Organic Standard addresses this concern in §205.238(a)(1). This section requires that producers choose livestock species and types suited to the site-specific conditions of the farm and those with natural resis- tance to prevalent diseases and parasites.